As much as I think vice taxes are a good idea, the panelists raised a lot of great points about the holes in Prop E.
It's only SF so people will just drive to Daly City to stock up on soda.
There are tons of other sugary products that won't be taxed - like milkshakes or candy.
It's a tax at the distributor level, so small businesses will just get their soda from outside the city.
Those types of arguments fail to impress me. They are the equivalent of "But Mikey's mom lets him ride his bike without a helmet?!"
Are we so naive to think that until the entire country or the entire world decides to implement the same tax that nobody should attempt to make progress?
So a tax that is regressive represents "progress"?
I assume your reference to "progress" is based on an assumption that the tax will produce the intended effect of forcing individuals to make healthier choices, but there's no evidence that this is the case. In fact, there's evidence that many consumers will just substitute in untaxed high calorie foods[1].
Cigarette taxes are regressive and definitely represent progress. They were a big help in reducing smoking, and in turn reducing smoking-related health problems.
Putting aside a debate over regressive taxes, the problem with your comparison is that you assume the market for sugary drinks functions the same way the market for cigarettes does when, in fact, studies have not found the same type of substitution dynamic[1].
In other words, "support soda taxes because cigarette taxes!" is not an argument based on any hard data. If you're going to argue for the use of taxation to force behavior, as a starting point you should have real evidence that the specific tax in question has a high likelihood of producing the specific behavior you're trying to change. Relying on some other tax that may have influenced another behavior is simply specious.
Also, if your view is "before you can do an experiment you must have hard data to prove the experiment will work" then it sounds like you aren't getting many experiments done.
Data already exists, and you can model against it. Apparently you didn't read the study I linked to:
> The study, published online in the American Journal of Agricultural Economics, found that a half-cent per ounce increase in sugar-sweetened beverage prices, which adds up to about ten cents on a typical 20-ounce bottle of soda, could reduce total calories from the 23 foods and beverages examined under the study.
> However, researchers found, the reduction in sugary beverages due to a soda tax would likely lead consumers to substitute for those beverage calories by increasing their calorie, salt and fat intake from untaxed foods and beverages.
> “Instituting a sugary beverage tax may be an appealing public policy option to curb obesity, but it’s not as easy to use taxes to curb obesity as it is with smoking,” said Chen Zhen, Ph.D., a research economist at RTI, and the paper’s lead author. “Consumers can simply substitute an untaxed high calorie food for a taxed one. And as we know, reducing calories is just one of many ways to promoting healthy eating and reducing nutrition-related chronic disease.”
Other studies[1] have come to similar conclusions, and note that much of the research predicting significant reductions in obesity are flawed because they failed to look at substitution.
If you are genuinely interested in implementing a tax ("experiment") that actually has a chance of producing the intended outcome irrespective of cost, the first study suggested that instead of taxing based on ounces, a tax based on calories would address some of the fundamental flaws in ounce-based taxes like those proposed in Prop E.
The study you linked to didn't even mention the word "sugar", so I'm not sure what you're talking about there. I'm not going to read an entire apparently unrelated study because some anonymous dude says it's relevant to an argument I'm not even making.
The news article you link to is about two attempts at this in the 1990s, looks broadly, covers places with a very different food culture than San Francisco, and treats obesity as the only relevant health issue from sugar. So I would call it interesting, but not necessarily relevant.
Moreover, you seem to ignore that this is a process. If the soda tax doesn't work, then people will try other things. But this is the thing on the ballot, and the question isn't, "Is this the best possible thing to do?" It's, "Shall we try this next?"
> The study, published online in the American Journal of Agricultural Economics, found that a half-cent per ounce increase in sugar-sweetened beverage prices, which adds up to about ten cents on a typical 20-ounce bottle of soda, could reduce total calories from the 23 foods and beverages examined under the study.
> However, researchers found, the reduction in sugary beverages due to a soda tax would likely lead consumers to substitute for those beverage calories by increasing their calorie, salt and fat intake from untaxed foods and beverages.
> “Instituting a sugary beverage tax may be an appealing public policy option to curb obesity, but it’s not as easy to use taxes to curb obesity as it is with smoking,” said Chen Zhen, Ph.D., a research economist at RTI, and the paper’s lead author. “Consumers can simply substitute an untaxed high calorie food for a taxed one. And as we know, reducing calories is just one of many ways to promoting healthy eating and reducing nutrition-related chronic disease.”
Because I presume that's what you were referencing when you said, "Apparently you didn't read the study I linked to."
That study is titled "How Effective are Taxes in Reducing Tobacco Consumption?" and continues not to mention the word sugar. Probably because it is about tobacco.
I might be wrong, but I'm responding to you because I think you're genuinely confused and not trolling.
You pointed to the efficacy of cigarette taxes in clear support of the Prop E tax ("Cigarette taxes are regressive and definitely represent progress. They were a big help in reducing smoking, and in turn reducing smoking-related health problems.").
I linked to multiple studies which found there was a strong likelihood consumers would simply substitute the taxed sugary beverages with untaxed foods that are just as unhealthy, calling into question the efficacy of such a tax.
I included a link to a study about cigarette taxes in support of my argument that "the problem with your comparison is that you assume the market for sugary drinks functions the same way the market for cigarettes does when, in fact, studies have not found the same type of substitution dynamic."
To make this simple for you:
1. Studies on sugary beverage taxes find strong substitution effects.
2. Studies on cigarette taxes do not find strong substitution effects.
Given this, your suggestion that taxes on sugary beverages are likely to have a similar level of efficacy to taxes on cigarettes is not congruent with the evidence. Instead of needing to explain this to you, you could have just read what I posted before responding to it. If you did that, you probably would have noticed what the lead researcher for one of the studies stated:
> “Instituting a sugary beverage tax may be an appealing public policy option to curb obesity, but it’s not as easy to use taxes to curb obesity as it is with smoking."
Hi! Thanks for the detailed reply. I see where things got confused.
> You pointed to the efficacy of cigarette taxes in clear support of the Prop E tax
No, I didn't.
You wrote "So a tax that is regressive represents 'progress'?"
I replied to that by giving an example of a regressive tax that represents progress. That's all. Your comment struck me as annoyingly glib, constructing a false contradiction through word games. Since cigarette taxes have been so successful, I thought it was a good counterexample to the false contradiction. Everything else you write is about what you read into my statement, not what I said.
But to address your point:
I agree that a sugary beverage tax in San Francisco could lead to substitution and no net health gain. But A) the circumstances are different enough (and the original sample size is small enough) that I'm happy to try it out to see what happens, and B) if it doesn't work like the proponents hope, I think that's fine because humans often have to try the obvious thing before they will try the less obvious thing.
Why do you think of those as negatives of the proposition itself? Those seem like arguments that it perhaps won't be as effective as supporters might hope, but not that the proposition itself is flawed.
(I'm actually unsure how I feel about the proposition at this point, so I'm just curious to hear some more discussion about it.)
It just feels too much like a symbolic victory rather than actual progress. I think it falls into the same category as the plastic bag ban - bags are a very small component of overall trash, but they're highly visible so let's ban them.
Who said they were about reducing total landfill volume? My understanding is that they're mainly about reducing litter. Which they've certainly done in my city.
It always takes one issue and one municipality at a time to make progress. Is marijuana decriminalization in Colorado a symbolic victory because people in the surrounding states and even here in California haven't yet experienced decriminalization.
Wouldn't if be great if we can one day get back to having robotic milkmen deliver milk in re-usable bottles?
This is a classic "if X is not perfect, there is no point to X" argument. Nobody sensible says, "This patch does not fix all the bugs in the module, so we shouldn't apply it!"
The only question I care about here is, "Is this going to improve the situation enough to justify the work?" So far, it looks like yes.
Marginal effect of tax != average effect of tax. Also, every objection you raise could have just as easily been leveled at cigarette taxes in the middle 20th century. In the long-run tobacco excise taxes have been a huge public health victory. I'm not accusing you of shilling for the ABA but you have pretty much repeated their talking points in your post. It just amazes me what an effective job they have done of distracting everybody from the obvious parallels to tobacco.
They are taxed at every single level of government. The feds have a ~$1/pack tax, plus whatever that state adds onto that. Then cities and counties are free to add on a tax too - New York and Chicago do. There might also be a general sales tax added to all of the above taxes. And of course sales tax can be at the state, county, and city level and said taxes are cumulative.
Some comments on the site, since the topic is kind of ridiculous... It's not immediately obvious you can click on the faces. Also, I'd like a better overview of what panelists have to say, but it's too much clicking to look at person individually. Finally, it could be helpful to write/generate a transcript to read versus the video to watch. Some might like the video for added cues, but it would be nice there was an alternative to watching 30 minutes of talking heads.
Transcript is a good idea, we've been looking into APIs & mechanical turk for that. In general we're trying to figure out how to present the responses in an interesting/informative way without you having to watch ALL the videos.
Generally when you run an in-person focus group or user interview, you're combining the interview time with the "watching" time since you're there in the same room. With instapanel, it's definitely faster than doing the interviews yourself, but there's no forcing function to watch the videos.
Reminds me of how my dad stopped watching talks at Xerox PARC once they started webcasting them. Without needing to show up for the talk at a specific time, he could always say "I'll watch that later".
Honestly, given that I have received circa 30 mendacious, bullshit-argument mailers during election season for this means I would be tempted to vote for E just to spite its opponents, whether or not this was workable.
But luckily, all their activity convinces me that the proposition will really work. The soda industry has spent FIFTEEN DOLLARS per SF voter on this. [1] This tells me that it's not just about San Francisco. They are scared that if it works here, others will soon follow suit, reducing their profits. So it seems they believe that this sort of tax will have a substantial impact on soda consumption. They're telling me that voting for E means a chance of improving the entire country's health. So I'm definitely in.
If we think of soda like tobacco this makes sense. If tobacco companies are against it, then it probably is a good idea.
But what if the book industry spent $15/SF voter to stop some law that applied to books? Perhaps that law would be harmful to book publishers AND to society overall.
It's amazing how soda companies have come to be seen as evil so quickly.
It's also amazing how quickly diet-related illness have become a national problem. [1]
Say, I see you work for Instapanel. Who paid for this? And who pays for Instapanel in general? The book thing seems like an odd enough comparison that I'm wondering where your interests lie.
We paid for this as a test of instapanel, got respondents off of Craigslist for $10 each. In general, we're building a tool for startups to get feedback like this on their own products.
I went in strongly in favor of Prop E, I came out as convinced that obesity and soda are bad, but less convinced that this law was a good way to address the issue. I'll probably still vote "Yes" on Prop E, but it was fun to hear the other side out.
I honestly had no strong opinion on the measure prior to the anti-campaign. I do think sugary drinks are a public health menace, but I did not think a tax is a good way to deal with them. Then: anti-E canvassers appeared at my door 3 times, I got about 5 robocalls, and about 10 pounds of glossy fliers in the mail. Clearly somebody with a deeply vested financial interest (not a public interest) doesn't want this to pass. So it definitely makes me consider researching the sugar tax a bit more and even consider voting for it.
I can't find the cite now, but I recently read that something like each 10% increase in the tobacco tax reduces smoking by 4%. so there seems to be good precedent for using taxes to reduce consumption.
The most substantiative arguments I've heard against the idea come from the angle of the tax being a regressive "punish the poor" item by being narrowly focused on the cheap added-sugar beverages, while exempting fruit juice and other equivalently concentrated forms. For the populists in the crowd, this is seen as a way to make this particular vice a privileged luxury.
Regardless, I'm going to vote yes; it really should be a luxury, we made a mistake back when we let it become a default option.
Edit: Oops that does have added sugar so it will also be taxed.
Edit 2: So it will not be taxed because it does not use artificial flavors? So you can put as much sugar as you want in something as long as it does not contain artificial flavoring? So is this actually an artificially flavored drink tax?
No: the proposition exempts products that contain only "natural fruit and vegetable juice", not "natural flavors" - the two are different. Some "natural flavors" are only natural in the sense they are derived from natural compounds, but are still synthesized in a lab.
Similarly, diet sodas - which do contain artificial flavors - are similarly exempt. You can read the ballot measure in full here:
So would that Odwalla drink I listed be exempt? It contains a ton of added sugar. So the rule is that if it has over 25 calories and and nothing manufactured in a lab you can add as much sugar as you want and be exempt?
My read would be that once you add cane sugar to something, it no longer contains "only fruit juice," but maybe that's not how it would work in practice. (hiou claims Odwalla's exempt, I don't know what that's based on though, maybe hiou meant one of the other Odwalla drinks that don't have added sugars, not sure).
Why do we subsidize sugar (High Fructose Corn Syrup through corn subsidies) one one end then tax it on the other? Seems like tax payers are double spending.
Because Iowa farmers get to vote on federal matters, but they don't get to vote in SF and NYC.
When I worked at Climate Corp, it was pretty interesting to hear the (nearly universally) Republican farmers argue for why there should be farm subsidies. About half wouldn't even try to justify it, and just said if the money's there I'll take it.
> About half wouldn't even try to justify it, and just said if the money's there I'll take it.
I'd respect those people more than the people who tried to argue it, as it's a case of don't hate the player hate the game (unless the player is rigging the game of course).
In this case, it's because Archer Daniels Midland can afford to buy enough federal representation to get the subsidies.
Sugar producers care more about the issue (because they get all the subsidies) than voters (for whom the subsidies are a small percentage of their tax bill). Plus, the subsidies represent a positive return on lobbying dollars, because there are a relatively small number of people to bribe. Sorry, I mean support.
This, however, was put on the ballot by local supervisors, and will be voted on by SF's population at large. That's a much harder dynamic to influence with money. Not that they aren't trying.
The government is not a single entity. There are various groups and conflicting interests, and it can be easier to do something that goes against a powerful lobby's interests on a local level. Corn subsidies are also meant to lead to stable food prices, which is something that benefits governing politicians. There are various conflicts of interest at work here.
I like the initiative, but it's weird to me that it taxes by oz, rather than by gram. So a sugar-packed shot-sized energy booster would be lightly taxed, while a 64 oz water or tea with a touch of sweet would get slammed by over a dollar.
That means there's no incentive for beverage makers to reduce sugars in popular drinks over time, to adjust people's palates towards something more normal.
Syrups added to flavor drinks are exempt. So maybe big drinks just adopt the tea/coffee model and involve a little more consumer stirring.
That said, maybe this breaks some new ground, and the model regulation improves upon it.
43 comments
[ 4.5 ms ] story [ 85.7 ms ] threadIt's only SF so people will just drive to Daly City to stock up on soda. There are tons of other sugary products that won't be taxed - like milkshakes or candy. It's a tax at the distributor level, so small businesses will just get their soda from outside the city.
Are we so naive to think that until the entire country or the entire world decides to implement the same tax that nobody should attempt to make progress?
I assume your reference to "progress" is based on an assumption that the tax will produce the intended effect of forcing individuals to make healthier choices, but there's no evidence that this is the case. In fact, there's evidence that many consumers will just substitute in untaxed high calorie foods[1].
[1] http://www.rti.org/newsroom/news.cfm?obj=5C84B2F7-5056-B100-...
In other words, "support soda taxes because cigarette taxes!" is not an argument based on any hard data. If you're going to argue for the use of taxation to force behavior, as a starting point you should have real evidence that the specific tax in question has a high likelihood of producing the specific behavior you're trying to change. Relying on some other tax that may have influenced another behavior is simply specious.
[1] http://tigger.uic.edu/~fjc/Presentations/Papers/taxes_consum...
Also, if your view is "before you can do an experiment you must have hard data to prove the experiment will work" then it sounds like you aren't getting many experiments done.
> The study, published online in the American Journal of Agricultural Economics, found that a half-cent per ounce increase in sugar-sweetened beverage prices, which adds up to about ten cents on a typical 20-ounce bottle of soda, could reduce total calories from the 23 foods and beverages examined under the study.
> However, researchers found, the reduction in sugary beverages due to a soda tax would likely lead consumers to substitute for those beverage calories by increasing their calorie, salt and fat intake from untaxed foods and beverages.
> “Instituting a sugary beverage tax may be an appealing public policy option to curb obesity, but it’s not as easy to use taxes to curb obesity as it is with smoking,” said Chen Zhen, Ph.D., a research economist at RTI, and the paper’s lead author. “Consumers can simply substitute an untaxed high calorie food for a taxed one. And as we know, reducing calories is just one of many ways to promoting healthy eating and reducing nutrition-related chronic disease.”
Other studies[1] have come to similar conclusions, and note that much of the research predicting significant reductions in obesity are flawed because they failed to look at substitution.
If you are genuinely interested in implementing a tax ("experiment") that actually has a chance of producing the intended outcome irrespective of cost, the first study suggested that instead of taxing based on ounces, a tax based on calories would address some of the fundamental flaws in ounce-based taxes like those proposed in Prop E.
[1] http://www.news.wisc.edu/22659
The news article you link to is about two attempts at this in the 1990s, looks broadly, covers places with a very different food culture than San Francisco, and treats obesity as the only relevant health issue from sugar. So I would call it interesting, but not necessarily relevant.
Moreover, you seem to ignore that this is a process. If the soda tax doesn't work, then people will try other things. But this is the thing on the ballot, and the question isn't, "Is this the best possible thing to do?" It's, "Shall we try this next?"
http://www.rti.org/newsroom/news.cfm?obj=5C84B2F7-5056-B100-...
> The study, published online in the American Journal of Agricultural Economics, found that a half-cent per ounce increase in sugar-sweetened beverage prices, which adds up to about ten cents on a typical 20-ounce bottle of soda, could reduce total calories from the 23 foods and beverages examined under the study.
> However, researchers found, the reduction in sugary beverages due to a soda tax would likely lead consumers to substitute for those beverage calories by increasing their calorie, salt and fat intake from untaxed foods and beverages.
> “Instituting a sugary beverage tax may be an appealing public policy option to curb obesity, but it’s not as easy to use taxes to curb obesity as it is with smoking,” said Chen Zhen, Ph.D., a research economist at RTI, and the paper’s lead author. “Consumers can simply substitute an untaxed high calorie food for a taxed one. And as we know, reducing calories is just one of many ways to promoting healthy eating and reducing nutrition-related chronic disease.”
http://ajae.oxfordjournals.org/content/early/2013/07/28/ajae...
Study name: Predicting the Effects of Sugar-Sweetened Beverage Taxes on Food and Beverage Demand in a Large Demand System
Study publication date: July 29, 2013
> I'm not going to read...
At this point I think it's fair to say that is precisely your problem.
https://news.ycombinator.com/item?id=8547734
Because I presume that's what you were referencing when you said, "Apparently you didn't read the study I linked to."
That study is titled "How Effective are Taxes in Reducing Tobacco Consumption?" and continues not to mention the word sugar. Probably because it is about tobacco.
You pointed to the efficacy of cigarette taxes in clear support of the Prop E tax ("Cigarette taxes are regressive and definitely represent progress. They were a big help in reducing smoking, and in turn reducing smoking-related health problems.").
I linked to multiple studies which found there was a strong likelihood consumers would simply substitute the taxed sugary beverages with untaxed foods that are just as unhealthy, calling into question the efficacy of such a tax.
I included a link to a study about cigarette taxes in support of my argument that "the problem with your comparison is that you assume the market for sugary drinks functions the same way the market for cigarettes does when, in fact, studies have not found the same type of substitution dynamic."
To make this simple for you:
1. Studies on sugary beverage taxes find strong substitution effects.
2. Studies on cigarette taxes do not find strong substitution effects.
Given this, your suggestion that taxes on sugary beverages are likely to have a similar level of efficacy to taxes on cigarettes is not congruent with the evidence. Instead of needing to explain this to you, you could have just read what I posted before responding to it. If you did that, you probably would have noticed what the lead researcher for one of the studies stated:
> “Instituting a sugary beverage tax may be an appealing public policy option to curb obesity, but it’s not as easy to use taxes to curb obesity as it is with smoking."
Good night.
> You pointed to the efficacy of cigarette taxes in clear support of the Prop E tax
No, I didn't.
You wrote "So a tax that is regressive represents 'progress'?"
I replied to that by giving an example of a regressive tax that represents progress. That's all. Your comment struck me as annoyingly glib, constructing a false contradiction through word games. Since cigarette taxes have been so successful, I thought it was a good counterexample to the false contradiction. Everything else you write is about what you read into my statement, not what I said.
But to address your point:
I agree that a sugary beverage tax in San Francisco could lead to substitution and no net health gain. But A) the circumstances are different enough (and the original sample size is small enough) that I'm happy to try it out to see what happens, and B) if it doesn't work like the proponents hope, I think that's fine because humans often have to try the obvious thing before they will try the less obvious thing.
I was questioning the validity of the arguments the parent commenter presented against Prop E.
Those are not arguments against the proposition based on its merits. They are arguments based on lack of universal implementation.
It doesn't matter how you feel about the actual proposition. I was claiming that the presented arguments were not convincing.
(I'm actually unsure how I feel about the proposition at this point, so I'm just curious to hear some more discussion about it.)
Wouldn't if be great if we can one day get back to having robotic milkmen deliver milk in re-usable bottles?
The only question I care about here is, "Is this going to improve the situation enough to justify the work?" So far, it looks like yes.
Generally when you run an in-person focus group or user interview, you're combining the interview time with the "watching" time since you're there in the same room. With instapanel, it's definitely faster than doing the interviews yourself, but there's no forcing function to watch the videos.
Reminds me of how my dad stopped watching talks at Xerox PARC once they started webcasting them. Without needing to show up for the talk at a specific time, he could always say "I'll watch that later".
But luckily, all their activity convinces me that the proposition will really work. The soda industry has spent FIFTEEN DOLLARS per SF voter on this. [1] This tells me that it's not just about San Francisco. They are scared that if it works here, others will soon follow suit, reducing their profits. So it seems they believe that this sort of tax will have a substantial impact on soda consumption. They're telling me that voting for E means a chance of improving the entire country's health. So I'm definitely in.
[1] http://www.sfgate.com/bayarea/article/Soda-industry-spends-7...
But what if the book industry spent $15/SF voter to stop some law that applied to books? Perhaps that law would be harmful to book publishers AND to society overall.
It's amazing how soda companies have come to be seen as evil so quickly.
Say, I see you work for Instapanel. Who paid for this? And who pays for Instapanel in general? The book thing seems like an odd enough comparison that I'm wondering where your interests lie.
[1] http://www.cdc.gov/chronicdisease/resources/publications/aag...
I went in strongly in favor of Prop E, I came out as convinced that obesity and soda are bad, but less convinced that this law was a good way to address the issue. I'll probably still vote "Yes" on Prop E, but it was fun to hear the other side out.
Regardless, I'm going to vote yes; it really should be a luxury, we made a mistake back when we let it become a default option.
http://www.odwalla.com/products/smoothies/strawberry-c-monst...
Edit: Oops that does have added sugar so it will also be taxed.
Edit 2: So it will not be taxed because it does not use artificial flavors? So you can put as much sugar as you want in something as long as it does not contain artificial flavoring? So is this actually an artificially flavored drink tax?
Similarly, diet sodas - which do contain artificial flavors - are similarly exempt. You can read the ballot measure in full here:
http://ballotpedia.org/City_of_San_Francisco_Sugary_Drink_Ta...
So this has a bunch of High Fructose Corn syrup
http://www.foodfacts.com/ci/nutritionfacts/Beverages-non-mil...
Does that count as exempt?
What exactly does "natural fruit and vegetable juice" actually mean? Concentrated orange juice often has citric acid added to it.
Tropicana Orange Juice from Concentrate has added "natural flavors". Does that make it taxed?
http://www.tropicana.com/#/trop_products/productsLanding.swf...
Odwalla's Strawberry C Monster contains "cane sugar" as an ingredient. http://www.odwalla.com/products/smoothies/strawberry-c-monst...
My read would be that once you add cane sugar to something, it no longer contains "only fruit juice," but maybe that's not how it would work in practice. (hiou claims Odwalla's exempt, I don't know what that's based on though, maybe hiou meant one of the other Odwalla drinks that don't have added sugars, not sure).
When I worked at Climate Corp, it was pretty interesting to hear the (nearly universally) Republican farmers argue for why there should be farm subsidies. About half wouldn't even try to justify it, and just said if the money's there I'll take it.
I'd respect those people more than the people who tried to argue it, as it's a case of don't hate the player hate the game (unless the player is rigging the game of course).
At least they are honest.
Sugar producers care more about the issue (because they get all the subsidies) than voters (for whom the subsidies are a small percentage of their tax bill). Plus, the subsidies represent a positive return on lobbying dollars, because there are a relatively small number of people to bribe. Sorry, I mean support.
This, however, was put on the ballot by local supervisors, and will be voted on by SF's population at large. That's a much harder dynamic to influence with money. Not that they aren't trying.
That means there's no incentive for beverage makers to reduce sugars in popular drinks over time, to adjust people's palates towards something more normal.
Syrups added to flavor drinks are exempt. So maybe big drinks just adopt the tea/coffee model and involve a little more consumer stirring.
That said, maybe this breaks some new ground, and the model regulation improves upon it.